ML21092A135

Rev 2 Public Comments ACRS Version

ML21092A135
Person / Time
Issue date:	05/05/2021
From:	Office of Nuclear Regulatory Research
To:
References
DG-1360, RG-1.205, Rev 2
Download: ML21092A135 (4)

Text

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Response to Public Comments on Draft Regulatory Guide DG-1360 Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants Proposed Revision 2 of Regulatory Guide (RG) 1.205 On December 16, 2020, the NRC published a notice in the Federal Register (85 FR 73088) that Draft Regulatory Guide, DG-1360 (Proposed Revision 2 of RG 1.205), was available for public comment. The Public Comment period ended on December 31, 2020. The NRC received comments from the organizations listed below. The NRC has combined the comments and NRC staff responses in the following table.

Comments were received from the following:

Victoria K. Anderson Seth Statler Technical Advisor, Engineering & Risk Director of Government Affairs Nuclear Energy Institute (NEI) National Fire Protection Association (NFPA) 1201 F Street NW, Suite 1100 50 F Street NW Washington DC 20004 Suite 625 Agencywide Document and Management System Washington, DC, 20740 (ADAMS) Accession No. ML21007A329 ADAMS Accession No. ML21007A331

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1360 Nuclear Energy Section 3, Section 3.3 - Fire PRAs utilize processes in NUREG/CR- The NRC staff agrees with this comment Institute Pages 22-24 7150, Volume 2 on hot short induced spurious operation and made the suggested change to DG-probability and duration. 1360.

Proposed resolution:

In order to acknowledge this and provide clarification in the event of any conflicts with Section 3.3, the following statement is recommended in Section 3.3 (following the paragraph in page 4 on shorting switches):

Guidance for circuit failure mode likelihood and hot short duration for use in Fire PRAs is included in NUREG/CR-7150, Volume 2.

Nuclear Energy Section 3.1, The following statement that is included in most, if not The NRC staff agrees with this comment Institute Page 19 all, license conditions, is not included in Section 3.1. and made the suggested change to DG-This License Condition does not apply to any 1360.

demonstration of equivalency under Section 1.7 of NFPA 805.

Proposed resolution:

Recommend including that statement at the end of (1)

Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1360 National Fire Section 2.2.3 NFPA supports the NRC in providing guidance to The NRC staff agrees with this comment.

Protection licensees efforts in gaining approval for alternative Association methods prescribed by NFPA 805 but recommends that The NRC staff revised DG-1360 to add the NRC revise the language of DG-1360, 2.2.3 to include the following sentence at the end of reference to NFPA 805, 1.7. This will not only clarify the Section 2.2.3:

alignment between DG-1360 with NFPA 805 but also reinforce the incorporation of NFPA 805 into 10 CFR Licensee self-approval of fundamental 50.48. FPP changes in NFPA 805 Chapter 3 may be granted in the fire protection license condition if the alternative is functionally equivalent or adequate for the hazard as appropriate. This license condition does not apply to changes made under NFPA 805, Section 1.7, Equivalency because NFPA 805, Section 1.7 requires that those changes be submitted to and approved by the NRC.

National Fire N/A Additionally, NFPA recommends that the NRC consider The NRC staff notes this comment.

Protection making future revisions to 10 CFR 50.48(c)(4) to reduce However, the actions suggested by the Association the redundant language with NFPA 805. comment would require rulemaking, which is beyond the scope of this regulatory guide.

National Fire N/A We recommend that efforts should focus on more closely The NRC staff notes this comment.

Protection aligning 10 CFR 50.48(c)(4) with NFPA 805 and more on However, the actions suggested by the Association what licensees must include in the technical comment would require rulemaking, documentation already required by NFPA 805, 1.7 versus which is beyond the scope of this providing Special Exemptions under 10 CFR 50.12. regulatory guide.

Draft Version for use at ACRS Full Committee Meeting on May 5, 2021 Commenter Section of Specific Comment NRC Resolution DG-1360 National Fire N/A The 2020 edition of NFPA 805 is the most advanced The NRC staff notes this comment.

Protection performance-based standard for fire protection within the However, the actions suggested by the Association industry and we strongly encourage its adoption into 10 comment would require rulemaking, CFR 50.48. which is beyond the scope of this regulatory guide.